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Issues Involved:
1. Permissibility of reservations u/s 15(4) of the Constitution in postgraduate medical courses. 2. Impact of reservations on societal advancement and merit. 3. Whether admission to postgraduate medical courses constitutes a promotional post. 4. Statutory regulations by the Indian Medical Council regarding reservations. Summary: Issue 1: Permissibility of Reservations u/s 15(4) The appellants contended that Article 15(4) does not permit reservation of seats in educational institutions. The Court rejected this argument, stating that the words "any special provision" in Article 15(4) are of wide amplitude and include reservation of seats in educational institutions. The Court referenced previous judgments, including M.R. Balaji v. State of Mysore and Indra Sawhney v. Union of India, to support the permissibility of reservations under Article 15(4). Issue 2: Impact of Reservations on Societal Advancement and Merit The appellants argued that reservations are detrimental to societal interests as they result in less competent doctors. The Court dismissed this assumption, referencing Indra Sawhney, which acknowledged that while reservations might imply selection of less meritorious persons initially, given an opportunity, members of backward classes can overcome initial disadvantages. The Court emphasized that reservations are provided only at the entry stage, and all candidates must meet the same proficiency standards to pass their examinations, thus addressing concerns about merit. Issue 3: Admission to Postgraduate Courses as Promotional Post The appellants argued that admission to postgraduate medical courses is akin to a promotional post and thus reservations should not be allowed. The Court found no substance in this argument, stating that admission to such courses cannot be equated to an appointment to a post or an appointment by promotion. Issue 4: Indian Medical Council Regulations The appellants and the Indian Medical Council contended that the regulations made by the Indian Medical Council prohibit reservations in postgraduate medical courses. The Court examined the Indian Medical Council Act and its provisions, concluding that the Act does not deal with or regulate admissions to graduate or postgraduate medical courses. The Court held that the regulations made by the Indian Medical Council are advisory and not binding, and cannot override the constitutional power under Article 15(4). The Court also noted that the 1992 recommendations by the Indian Medical Council had not been approved by the Central Government and thus could not govern admissions. Conclusion: The Court dismissed the appeals, upholding the provision for reservations in postgraduate medical courses as permissible under Article 15(4) and not in conflict with the Indian Medical Council regulations. The Court emphasized the need to harmonize constitutional provisions and statutory regulations, ensuring that reservations aim to achieve social justice without compromising educational standards.
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